Polaris Urges FCC Emergency Ruling on 9-1-1 Indoor Location Rules
Tuesday, June 02, 2020 | Comments

Polaris Wireless submitted a petition requesting the FCC to release an emergency declaratory ruling reaffirming the deadlines established in the fifth report and order on 9-1-1 location technology. Polaris said the Z-axis proceedings have reached a critical point that necessitates such clarity if the deadlines set by the commission are to be met. Polaris said the FCC should dismiss without prejudice the “alternative proposals belatedly and hastily advanced by certain interests.”

Polaris said the proposals were submitted under seal so that they cannot be evaluated and are predicated on the commission’s belated and unwarranted acceptance of an accuracy standard, which the public-safety community has repeatedly stated is not sufficient. The company said that meeting the current deadline is still possible, but time is running out for carriers to act as necessary to comply with the mandated deadline.

The FCC adopted the new rules Nov. 22. Based on recent developments in the docket, to meet the established April 2021 deadline, the commission must reconfirm that the order stands as written and that alternative proposals will not be considered in this docket, the Polaris petition said.

Instead of working on implementation approaches for demonstrated capabilities from Stage Z vendors, the nationwide carriers now offer a revised vertical location framework or alternative path for Z-axis compliance, Polaris said. These proposals offer nationwide Z-axis coverage — an increase from the top 25/50 cellular market areas (CMAs) — but with 3-meter accuracy for 80% of calls not delivered until 2025, a weakened proposal for the top 25/50 CMAs. Clearly, these proposals seek to change z-axis compliance in the adopted order to performance achievable by one technology vendor, Google, Polaris said in its filing.

Last month, CTIA officials discussed generally the most recent 9-1-1 Location Technologies Test Bed testing of 9-1-1 vertical (Z-axis) location technologies, Stage Za, in an FCC filing, but the full report is unavailable to the public. Stage Za reviewed a single emergency location solution, Google’s Android-based Emergency Location Service (ELS).

NextNav and Polaris Wireless can provide service beyond the top 50 markets, the filing said. “The CTIA and the carriers’ actions seem to argue that Z-axis capabilities offered by Polaris Wireless and NextNav cannot co-exist with device-based solutions and that a trade-off is the only option,” Polaris said. “In fact, Polaris Wireless has offered to all carriers and many public stakeholders, including other location technology vendors, to collaborate on a combined solution that would serve the most consumers in with the greatest possible geographic coverage area. There is no technical hurdle preventing such a collaboration.”

In February, wireless carriers abandoned the National Emergency Address Database (NEAD), the platform designed to support wireless providers’ provision of dispatchable location information to 9-1-1 centers.

“Further, the timing of the carriers’ sudden advocacy for weakening the Z-axis accuracy standard to accommodate solutions incapable of meeting the current mandate is troublesome given the docket’s history,” Polaris said. “The carriers collectively failed to develop the NEAD and abandoned that solution without any alternative dispatchable location recommendations. Now, the carriers are promoting a weakened path to compliance in support of OS vendor device-based hybrid solutions, of which only one of two has been tested and the one tested fell short of performance mandated in the order.”

The full Polaris filing is here.

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